Translation from Norwegian
Complaint No.: 11762579 10094/11-115 / SHO017 Doc.No.: 03
Indictment
THE PUBLIC PROSECUTORSOFOSLO
hereby indict Anders Behring Breivik, born 13.02.1979currently remanded in custodybefore the Oslo District Court, pursuant to section 39 of the Penal Code, for sentence to be passedfor his transfer to compulsory mental health care, cf. chapter 5 of the Mental Health Care Act, forhaving in a psychotic state committed an otherwise punishable act, namely in violation of:
I
Section 147a of the Penal Code, first paragraph letters a and b, cf. sections 148 first paragraphfirst penalty alternative and 233 first and second paragraphs
for having committed a terrorist act in violation of section 148 of the Penal Code, first paragraph, firstpenalty alternative (bringing about an explosion whereby loss of human life or extensive damage to theproperty of others could easily be caused) and of section 233 first and second paragraphs (premeditatedmurder where particularly aggravating circumstances prevail) with the intention of seriously disrupting afunction of vital importance to society, such as the executive authority or seriously intimidating apopulation.
Grounds:
On 22 July 2011 at approximately 15.17 in Grubbegata in Oslo, following prior deliberations andplanning, he did park a VWQ Crafter van with registration number BR 99834 outside the entrance of theH-Block of the Government Office Quarter, housing inter alia the offices of the Prime Minister andMinister of Justice. At the time, a total of at least 250 persons were in the H-block and surroundingministry offices and some 75 persons in the streets in the immediate vicinity thereof. In the vehicle, hehad placed a self-made bomb weighing approx. 950 kg, consisting inter alia of artificial fertilizer, dieseland aluminium. He ignited a fuse with a burn time of some seven minutes and thereafter left the sceneon foot to a previously parked getaway car, a Fiat Duplo with registration number VH 24605. The bomb
detonated at 15.25.22 with a violent fire power and shock wave in keeping with his intentions, bringing alarge number of persons who found themselves in the buildings of the Government Offices or at streetlevel into immediate mortal danger, and causing massive material damage to the same buildings, as wellas to surrounding buildings.
SEO005
2
By means of the explosion, he did kill the following eight persons, who all sustained extensive blastinjuries:
1. Jon VegardLervåg, born 17 February 1979
He was at the entrance of the H-block and close to the van and died immediately.
2. Ida Marie Hill, born 20 February 1977
She was at the entrance of the H-block and close to the van and died immediately.
3. Hanne Ekroll Løvlie, born 29 June 1981
She was outside the entrance to the H-block and died quickly.
4. Anne LiseHolter, born 16 September 1959
She was in the reception area on the ground floor of the H-block and died immediately.
5. Hanne Marie Orvik Endresen, born 21 March 1950
She was in the reception area on the ground floor of the H-block and died immediately.
6. Kjersti Berg Sand, born 10 October 1984
She was in the reception area on the ground floor of the H-block and died immediately.
7. Kai Hauge, born 31 July 1978
He was in Grubbegata next to the driveway leading to the main entrance of the H-block and died immediately.
8. ToveÅshillKnutsen, born 31 July 1954
She was in the proximity of the fountain at EinarGerhardsens Square and died quickly.
By means of the explosion, he did also attempt to kill a large number of persons, including the otherswho found themselves in the H-block and surrounding streets. He did not succeed in his intention, butnine persons sustained serious physical injuries, as follows:
9. Male, born 23 August 1949
He was in the proximity of the fountain at EinarGerhardsen’s Square.
10. Female, born 17 July 1964
She was in the proximity of the fountain at EinarGerhardsen’sSquare.
11. Male, born 16 February 1986
He was in Grubbegata at EinarGerhardsen’sSquare.
12. Male, born 24 May 1944
He was on the 4th floor of the H-block, in an office facing Grubbegata.
13. Female, born 21 September 1987
She was in the reception on the ground floor of the H-block.
14. Female, born 13 February 1950
She was on the 7th floor of the H-block.
15. Female, born 8 May 1961
She was on the 10th floor of the H-block.
16. Male, born 7 November 1980
He was on the 1st floor of the government building R4 in an office facing Grubbegata.
17. Female, born 20 April 1956
She was at Johan Nygaardsvold’s Square between the H-block and Akersgata.
Moreover, a further 200 persons at least were physically injured as a result of the explosion, displayingvarying injury patterns, such as cuts, fractures and hearing impairments, of which many were treated inhospital/emergency clinic or given other medical treatment. In addition, many of the above-statedinjured persons and others who found themselves in the vicinity of the explosion, as well as survivingrelatives/next of kin have suffered mental after-effects of varying gravity caused by the events describedabove.
The bomb explosion resulted in the inability of a number of government offices, including the Office ofthe Prime Minister, the Ministry of Justice and Public Security, the Ministry of Trade and Industry, theMinistry of Petroleum and Energy, the Ministry of Health and Care Services, the Ministry of Labour, theMinistry of Finance, the Ministry of Education and Research, to be used, and the ministries affectedwere unable to attend to and carry out their functions as executive powers before a certain period of timehad elapsed. The explosion and the effects thereof have also given rise to serious fear in parts of theNorwegian population.
II
Section 147a of the Penal Code, first paragraph letter b, cf. section 233 first and second
paragraphs
for having committed a terrorist act in violation of section 223 of the Penal Code, first and secondparagraphs (premeditated murder where particularly aggravating circumstances prevail) with theintention of seriously intimidating a population.
Grounds:
On Friday 22 July 2011, subsequent to having acted as described in detail under count I, he did drive inthe getaway car to the municipality of Hole where he knew that the organization AUF (Workers’ YouthLeague) were holding their traditional summer camp on the island Utøya. There were 564 persons onthe island. By posing as a police officer and dressed in a uniform-like outfit, he was transported –carrying inter alia a Ruger-brand Mini 14 semi-automatic rifle cal. 233 and a Glock-brand semiautomaticl 9 mm pistol – to Utøya onboard the ferry M/S Thorbjørn, where he disembarked atapproximately 17.15. Up until the time of his arrest by the police on the same day at approximately18.35, he did shoot, following prior deliberations and planning, with his rifle and/or pistol, at a numberof persons who were on the island, in the water or onboard boats, including civilians who came to theirrescue, exposing them to immediate mortal danger. Panic and mortal fear in children, youth and adultsarose during the shooting, further intensified by the fact that there were limited possibilities of escape orhiding. While moving around the whole island, he did shoot at persons running away and/or hidingand/or whom he lured to appear from hiding with information that the police had arrived.
He did kill 69 persons, of whom 67 were hit by fatal gunshots, fired by the described weapons. Twopersons died as a result of fall injuries and/or drowning while attempting to get away, without havingbeen hit by gunshots. The persons killed are as follows:
1. TrondBerntsen, born 12 May 1960
He was between the Information Building and the pier. Shot dead..
2. Monica Elisabeth Bøsei, born 20 January 1966
She was standing between the Information Building and the pier. Shot dead.
3. Rune Havdal, born 16 December 1967
He was standing between the Information Building and the café. Shot dead.
4. Hanne Anette Balch Fjalestad, born 13 October 1967
She was outside the main entrance of the café. Shot dead.
5. Snorre Haller, born 29 April 1981
He was outside the main entrance of the café. Shot dead.
6. Rolf Christopher Johansen Perreau, born 9 June 1986
He was outside the main entrance of the café. Shot dead
7. LejlaSelaci, born 9 January 1994
She was in front of the café. Shotdead.
8. Steinar Jessen, born 17 January 1995
He was in the vicinity of the outdoor stage next to the café. Shot dead.
9. BirgitteSmetbak, born 25 February 1996
She was in the tent camp next to the café or inside the building itself. Shot dead.
10. Gunnar Linaker, born 07 July 1988
He was in the tent camp southwest of the café. Shot dead.
11. MargretheBøyumKløven, born 3 March 1995
She was in the doorway between the Little Hall and the Big Hall of the café. Shot dead.
12. Silje Merete Fjellbu, born 13 November 1993
She was in the Little Hall of the café. Shot dead.
13. GuroVartdalHåvoll, born 17 June 1993
She was in the Little Hall of the café- Shot dead.
14. Ronja Søttar Johansen, born 3 February 1994
She was in the Little Hall of the café. Shot dead.
15. Mona Abdinur, born 3 February 1993
She was in the Little Hall of the café. Shot dead.
16. SondreKjøren, born 16 June 1994
He was in the Little Hall of the café. Shot dead.
17. BendikRosnæsEllingsen, born 26 January 1993
He was in the Little Hall of the café. Shot dead.
18. EivindHovden, born 26 January 1996
He was in the Big Hall of the café. Shot dead.
19. Lene Maria Bergum, born 16 March 1992
She was in the Big Hall of the café. Shot dead.
19. Elisabeth Trønnes Lie, born 9 March 1995
She was in the Big Hall of the café. Shot dead.
21. Henrik André Pedersen, born 19 February 1984
He was in the Big Hall of the café. Shot dead.
22. Ida BeatheRogne, born 8 November 1993
She was in the Big Hall of the café. Shot dead.
23. Aleksander Aas Eriksen, born 29 August 1994
He was in the corridor further in from the Little Hall of the café. Shot dead.
24. Eva KathinkaLütken, born 3 July 1994
She was on the Kjærlighetsstien (Lovers’ Path). Shot dead.
25. Tore Eikeland, born 18 May 1990
He was on Kjærlighetsstien. Shot dead.
26. Tarald Kuven Mjelde, born 23 January 1993
He was on Kjærlighetsstien. Shot dead.
27. Maria MaagerøJohannesen, born 24 March 1994
He was on Kjærlighetsstien. Shot dead.
28. Monica Iselin Didriksen, born 18 February 1993
She was on Kjærlighetsstien. Shot dead.
29. Åsta Sofie Helland Dahl, born 19 November 1994
She was on Kjærlighetsstien. Shot dead.
30. Anders Kristiansen, born 30 January 1993
He was on Kjærlighetsstien. Shot dead.
31. BanoAbobakar Rashid, born 28 December 1992
She was on Kjærlighetsstien. Shot dead.
32. Andreas Edvardsen, born 30 November 1992
He was on Kjærlighetsstien. Shot dead.
33. SiljeStamneshagen, born 15 May 1993
She was on Kjærlighetsstien. Shot dead.
34. SondreFurseth Dale, born 19 February 1994
He was at the water’s edge between the escarpment below Kjærlighetsstien and Nakenodden
(Naked Point). Shot dead.
35. Simon Sæbø, born 25 July 1992
He was in the area close to the escarpment below Kjærlighetsstien. Shot dead.
36. Modupe Ellen Awoyemi, born 14 August 1995
She was on the uppermost part of the escarpment below Kjærlighetsstien. Shot dead.
37. SharidynMeeganNgahiwiSvebakk-Bøhn, born 17 July 1997
She was in the area by the escarpment below Kjærlighetsstien. Shot dead.
38. Marianne Sandvik, born 14 March 1995
She was in the area by escarpment below Kjærlighetsstien. Shot dead.
39. GizemDogan, born 1 May 1994
She was in the woods east of the school building. Shot dead.
40. Johannes Buø, born 5 November 1996
He was in the woods east of the school building. Shot dead.
41. Even FlugstadMalmedal, born 6 December 1992
He was at the water’s edge at Stoltenberget (Stoltenberg Rock). Shot dead.
42. Syvert Knudsen, born 21 August 1993
He was at Stoltenberget. Shotdead.
43. Synne Røyneland, born 18 January 1993
She was at Stoltenberget, in all likelihood in the water/at the water’s edge. Shot dead.
44. TorjusJakobsenBlattmann, born 19 September 1993
He was in Bolsjevika (Bolshevik Cove). Shot dead.
45. Ingrid Berg Heggelund, born 20 September 1992
She was in Bolsjevika. Shot dead.
46. Isabel Victoria Green Sogn, born 18 March 1994
She was in Bolsjevika. Shot dead.
.
47. Karar Mustafa Qasim, born 22 February 1992
He was in Bolsjevika. Shot dead.
48. Carina Borgund, born 25 March 1993
She was in Bolsjevika. Shotdead.
49. Tina Sukuvara, born 2 September 1992
She was in the area of the pump house. Shot dead.
50. Ruth BenedichteVatndal Nilsen, born 1 October 1995
She was in the area of the pump house. Shot dead.
51. Henrik Rasmussen, born 18 February 1993
He was in the area of the pump house. Shot dead.
52. EspenJørgensen, born 6 June 1994
He was in the area of the pump house. Shot dead.
53. PorntipArdam, born 18 January 1990
She was by the pump. Shot dead.
54. Thomas MargidoAntonsen, born 25 June 1995
He was by the pump house. Shot dead.
.55. IsMayl Haji Ahmed, born 23 August 1991
He was by the pump house. Shot dead.
56. Fredrik Lund Schjetne, born 16 August 1992
He was by the pump house. Shot dead.
57. Hanne Kristine Fridtun, born 15 August 1991
She was by the pump house. Shot dead.
58. Emil Okkenhaug, born 2 November 1995
He was by the pump house. Shot dead.
59. HåvardVederhus, born 10 November 1989
He was by the pump house. Shot dead.
60. Victoria Stenberg, born 23 October 1993
She was by the pump house. Shot dead.
61. Sverre Flåte Bjørkavåg, born 1 January 1983
He was in the area of the pump house. Shot dead.
62. DiderikAamodt Olsen, born 3 June 1992
He was in the area of the pump house. Shot dead.
63. TamtaLiparteliani, born 7 January 1988
She was at the water’s edge at Sydspissen (South Point). Shot dead.
64. Kevin DaaeBerland, born 24 June 1996
He was at the water’s edge at Sydspissen. Shot dead.
65. Karin Elena Holst, born 18 August 1995
She was at the water’s edge at Sydspissen. Shot dead.
66. RafalMohamadJamilJamil, born 5 March 1991
She was at the water’s edge at Sydspissen. Shot dead.
67. AndrineBakkeneEspeland, born 30 July 1994
She was at the water’s edge at Sydspissen. Shot dead.
68. HåkonØdegaard, born 18 May 1994
He fled from the island by starting to swim, but died of drowning and was found outside
Sydspissen.
69. Andreas DalbyGrønnesby, born 16 July 1994
He fled and fell off a cliff near the island’s west point and into the water. Died of fall injuries and/or drowning.
In addition to the above-stated murders, he did attempt to kill a number of other persons, albeit withoutsucceeding in his intentions. In the course of the attempted murders, he did shoot and injure 33 personsas follows:
70. Female, born 11 March 1991
She was in the tent camp and was shot.
71. Male, born 2 November 1991
He was in the tent camp and was shot.
72. Female, born 16 March 1992
She was in the tent camp and was shot.
73. Female, born 23 December 1994
She was in the tent camp and was shot.
74. Female, born 7 July 1996
She was in the tent camp and was shot.
75. Female, born 11 April 1995
She was in the tent camp and was shot.
76. Female, born 12 December 1994
She was in the tent camp and was shot.
77. Female, born 29 December 1989
She was in the Little Hall of the café and was shot.
78. Female, born 4 September 1994
She was in the Little Hall of the café and was shot.
79. Male, born 11 December 1993
He was in the Little Hall of the café and was shot.
80. Male, born 5 November 1991
He was in the Little Hall of the café and was shot.
81. Female, born 19 February 1990
She was in the doorway between the Little Hall and the corridor of the café and was shot.
82. Male, born 10 March 1992
He was first in the Big Hall of the café and was shot.
83. Female, born 16 March 1992
She was in the Big Hall of the café and was shot.
84. Female, born 9 March 1994
She was on Kjærlighetsstien and was shot.
85. Female, born 23 September 1993
She was on a ledge of the escarpment below Kjærlighetsstien and was shot.
86. Male, born 4 August 1993
He was at the water’s edge below Kjærlighetsstien and was shot.
87. Female, born 3 March 1992
She was between the water’s edge and Kjærlighetsstien and was shot.
88. Male, born 19 August 1993
He was in the water below Kjærlighetsstien and was shot.
89. Female, born 12 January 1994
She was in the escarpment below Kjærlighetsstien and was shot.
90. Female, born 26 September 1996
She was in the escarpment below Kjærlighetsstien and was shot.
91. Female, born 7 July 1994
She was on a ledge below Kjærlighetsstien and was shot.
92. Male, born 28 January 1992
He was on a ledge below Kjærlighetsstien and was shot.
93. Female, born 5 January 1995
She was at the pump house and was shot.
94. Male, born 8 February 1991
He was at the pump house and was shot.
95. Male, born 10 August 1990
He was at the pump house and was shot.
96. Male, born 29 May 1995
He was in the vicinity of Vestspissen (West Point) and was hit by a number of projectile
fragments from shots.
97. Male, born 29 January 1996
He was in the vicinity of Vestspissen and was shot.
98. Male, born 8 December 1989
He was at Sydspissen and was shot.
99. Female, born 11 October 1994
She was at Sydspissen and was shot.
100. Female, born 31 August 1993
She was at Sydspissen and was shot.
101. Female, born 26 November 1993
She was at Sydspissen and was shot.
102. Female, born 23 June 1993
She was at Sydspissen and was shot.
A number of other persons who were on Utøya sustained physical injuries, such as fractures, cuts, etc. in
their attempts to save themselves and others. In addition, a large number of persons who were on theisland, surviving relatives/next of kin, as well as persons who came to rescue in boats and by othermeans have suffered mental after-effects of varying gravity as a result of the above-described events.The acts committed at Utøya have given rise to serious fear in parts of the Norwegian population.
*
The defendant has committed extremely serious offences on a scale that has never previously beenexperienced in our country in modern times. In the defendant’s own opinion, these acts have beenlegitimate and lawful, and there is undoubtedly an obvious and evident fear that new serious offences ofthe same nature may reoccur. Considerations of public safety require a sentence ordering his transfer tocompulsory mental health care, and the conditions set out in section 39 No. 1 have been met.
Section 49 of the Penal Code applies to count I, items 9 to 17, and count II, items 70 to 102, of theIndictment
Submission will be made for the confiscation of three weapons (a Ruger-brand semi-automatic Mini 14rifle cal. 233, a Glock-brand 9 mm semi-automatic pistol and a Benelli-brand pump shotgun) with theappurtenant ammunition. Furthermore, submission will be made for the confiscation of objects used tomanufacture the bomb mentioned under count I of the Indictment, as well as any clothing/equipment,etc. used during the commission of the acts described under counts I and II.